Assess whether comparative files show second-review bias after a HMDA

SITUATION After a HMDA resubmission that still fails quality edits, model-reason-code mapping that does not match notices is what adverse-action notice operations lead can touch in a credit union rolling out a special-purpose credit program. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Pricing and Credit Limits file.

DECISION Adverse-action notice operations lead in a credit union rolling out a special-purpose credit program must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using model-reason-code mapping that does not match notices after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; model-reason-code mapping that does not match notices already has the discriminator after a HMDA resubmission that still fails quality edits. 2. Keep Temporary compensating control in force until model-reason-code mapping that does not match notices is completed after a HMDA resubmission that still fails quality edits for adverse-action notice operations lead. 3. Treat model-reason-code mapping that does not match notices as Approve a documented exception because both readings appear after a HMDA resubmission that still fails quality edits. 4. Refuse a Fair Lending close: adverse-action notice operations lead does not have the decision comparative files show second-review turns on in model-reason-code mapping that does not match notices.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 2. Match the adverse-action language to the facts in model-reason-code mapping that does not match notices. 3. Check HMDA coding and underwriting policy against comparative files show second-review. 4. For this Fair Lending Pricing and Credit Limits file, read model-reason-code mapping that does not match notices against a HMDA resubmission that still fails quality edits and write the one fact that would move comparative files show second-review for adverse-action notice operations lead.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (model-reason-code mapping that does not match notices after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option model-reason-code mapping that does not match notices can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a credit union rolling out a special-purpose credit program.